Important insight from the organic certification approach to chemical additives in food

Tom Neltner, J.D.is Chemicals Policy Director

Since 2014, chemicals in food[1] have been consumers’ most important food safety issue, reaching a high of 35% in 2018, according to annual industry surveys by the International Food Information Council. For comparison, “foodborne illness from bacteria” was half that percent.

Food companies have responded to this growing consumer alarm by adopting policies banning artificial flavors, colors and other ingredients that sound like chemicals. This approach is unlikely to do more than serve as window dressing for the underlying problems since it’s not science-based – many of these additives may be safe. The Center for Science in the Public Interest called out this practice in its 2017 “Clean Label: Public Relations or Public Health?” report and pointed readers to its Chemical Cuisine system that rates common additives for health and safety.

There are some companies, like Panera Bread, that are taking a more systematic approach to the ingredients used in the food they sell, starting with the question of whether the additives used are essential and whether the ingredients pose health or safety concerns. As a result, the company worked closely with their suppliers and reformulated many of their products.

And now, thanks to a fascinating new report from the Environmental Working Group (EWG), we are learning about another structured approach that addresses health concerns with chemical additives – the Federal organic certification program for processed foods. To be honest, before reading the report, I viewed the organic program as narrowly focused on pesticides and was only vaguely aware of how it dealt with chemical additives. I was missing the bigger picture.

According to the report, the organic certification program run by the National Organic Standards Board (NOSB) prohibits “synthetic substances” that have an adverse effect on human health from use in processed organic food. It also considers other factors, such as adverse impact on the environment, nutritional value, and availability of a natural alternative. The NOSB allows use of these chemical additives only after evaluation through a transparent review process that invites public participation. The final decision is promulgated in a rule. In addition, decisions must be reassessed every five years. Currently, fewer than 40 synthetic chemical additives are allowed in certified organic processed food.

The table below compares the mandatory NOSB review process to the one for chemical additives in conventional processed foods.

Comparison of government-mandated safety review for chemical additives in processed food

 Organic processed foodConventional processed food
Number of chemical additives currently allowed to be addedFewer than 40 synthetic substancesAbout 2,500 chemical additives*
Government review for safety neededYesNo – voluntary, due to Generally Recognized as Safe (GRAS) loophole
Reviewing agencyNational Organic Standards Board (NOSB)Food and Drug Administration (FDA) only when requested by industry
Public comments invitedYesLimited**
Frequency of reassessment for safetyEvery five yearsOnly if prompted by safety concerns
* Based on Neltner, et al., Navigating the U.S. Food Additive Regulatory Program, 2011.
**Almost all of FDA reviews for new chemical additives to food go through the GRAS Notification Program, but it only occurs when voluntarily requested by industry. That program does not invite or provide a means for the public to comment. When comments are submitted, the agency does not have to respond to them. In those few cases where the agency is evaluating a food additive petition, there is an opportunity to comment and the agency must respond to comments.

Note that the organic certification process does not address the more than 3,800 chemicals currently allowed by FDA for use in packaging or food handling equipment. Due to the Generally Recognized as Safe (GRAS) loophole, these additives – regardless of their use with organic or conventional processed foods – are only reviewed by FDA if a company chooses to request review.

Despite limitations in the chemical additives allowed, processed organic food is apparently meeting consumer demands for quality, safety and shelf-life because its share of the marketplace is growing quickly. This serves as a compelling counterpoint to the conventional processed food industry’s argument that it needs a palette of more than 2,500 chemical additives to meet consumer demands. The EWG report sheds new light on this argument that industry has long wanted us to believe.

At EDF, we want all foods to be safe and healthy. FDA’s food additive program isn’t ensuring food is safe, given how many chemicals are allowed to be used in food, packaging, and handling equipment that have not been reviewed for safety using modern science. To fix the food additive program, we must end secrecy by closing the GRAS loophole, use modern science to evaluate chemicals, and ensure existing chemicals are safe. FDA must be given the tools and funding it needs to set priorities and make decisions.

Finally, I am not suggesting that the organic certification process is perfect or that 40 chemical additives are sufficient to make the range of foods that consumers want. Clearly, the manufacturers are yet to tackle chemicals in food from packaging and food handling equipment which can pose health risks. And the accessibility and cost disparity between processed organic and conventional food raises equity concerns about people being priced out of the organic market. However, the organic certification approach to chemical additives that relies on transparency, public engagement, and a systematic reassessment serves as a potential model that should be considered to address consumers’ growing concern with chemicals in their food.

[1] The International Food Information Council varies the specific categories. For 2018, I combined the categories of “carcinogens or cancer-causing chemicals in food”, “chemicals in food”, and excluded “food additives and ingredients”, “pesticides / pesticide residues”, and “animal antibiotics.”

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